Original Date: 10/20/1997
Revision Date: 01/18/2007
Best Practice : Environmental Management Program
Northrop Grumman implemented an extremely proactive Environmental Management Program (EMP) which could be used as a model for many U.S. industries. The key to the program’s success is the commitment by Northrop Grumman’s management to have zero environmental deficiencies within the organization.
An environmental staff manages the EMP by first laying out a regulatory roadmap of those environmental issues on the horizon which need to be addressed. Next, they develop action plans and milestones for implementing the plans across all divisions and departments within the Corporation. By having a very thorough understanding of the plant operations and processes, the environmental staff is able to implement process and equipment changes in advance of regulatory requirements.
An example of the proactiveness and commitment of the EMP is the self-imposed monthly inspections of all daily operations. In this program, members of the environmental staff conduct monthly pre-audits of all work areas in the facility. An extensive checklist is used to cover all environmental compliances that are needed for that particular area. The data and results of this pre-audit are coded and discussed with the area supervisor. The coded data collection system consists of a standardized format and contains a list of the most common major deficiencies found in industry and in violation of regulatory requirements (e.g., environmental records/manuals not centrally located and available for inspection; less than three years of training records; volatile organic compound limit exceeded for permit or material; no hazardous waste satellite inspection reports). Statistical analysis of the data is also performed to identify deficiency trends and further employee training requirements. From this data, a written report is generated and given to the supervisor for action, if required. Ten days later, another audit is conducted of the area. The final report, generated from this audit, is forwarded to the cost center vice president. Figure 2-1 shows the results of Northrop Grumman’s internal audits during the first nine months of 1997.
Focal points are established within each work area, and monitors are responsible for the administrative recordkeeping and daily inspections of those areas. Monitors are employees from the localized work area who have received special and ongoing training in environmental requirements and compliance. If a work area passes two successive monthly audits with no deficiencies, all of the employees in that work area are given special recognition and rewarded appropriately.
Ongoing training of all personnel in the organization is paramount to the success of any environmental management program. This effort is evidenced at Northrop Grumman by the fact that the company has had zero regulatory agency penalties during the last three years. Several initiatives are also underway to ensure that Northrop Grumman will continue to be good stewards of the community and a leader in the environmental management arena.
Figure 2-1. Major Deficiency Summary
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